Annex A

Complaint Procedures

Receipt of Complaints

1. Telephone Hotline: Any person with a Complaint can call +86-10-6621-0625 to submit his or her Complaint by leaving a telephone message. Employees who call this number may, but need not, leave their name, telephone number, email address or other personal information and the investigation that follows from any employee call will be conducted in a manner that protects the confidentiality and anonymity of the employee making the call to the fullest extent possible, consistent with the need to conduct an adequate review. The intake telephone message will be reviewed by a member of the Audit Committee designated to review hotline telephone messages. The designated Audit Committee member shall review the hotline telephone messages at least twice a week. The person administrating the hotline shall notify the designated Audit Committee member as soon as a new telephone message has been recorded. Among other things, the following information should be given to the person reviewing the telephone message:
• If an employee, the division of the company in which the caller works and, if a non-employee, where such person is employed or such person’s relationship to the company;
• Any relevant information concerning the allegations;
• Name, telephone number and / or email address of the caller (unless an employee decides to remain anonymous, in which case, other channels of communication through which the designated Audit Committee member may initiate an adequate review of the allegations).

The information from the call will be documented in a format acceptable to the Company and the Audit Committee and shall include at a minimum a written description of the information received concerning the Complaint allegations.

2. Written Complaints: Any person may submit a written Complaint to the Chairman of the Audit Committee at either knlee@starhub.net.sg or to the following address: 58 Belmont Road, Singapore 269890. Employees submitting this information may, but need not, provide their name, telephone number, email address or other personal information and the investigation that follows from a Complaint from an employee will be conducted in a manner that protects the confidentiality and anonymity of the employee submitting the Complaint to the fullest extent possible, consistent with the need to conduct an adequate review.

Treatment of Complaints

1. A Complaint made under these procedures will be directed to the full Audit Committee or other designated management personnel who will report directly to the Audit Committee on such matters.
2. The Audit Committee will review the Complaint, and may investigate such Complaint itself or may assign another employee, outside counsel, advisor, expert or third-party service provider to investigate, or assist in investigating the Complaint. The Audit Committee may direct that any individual assigned to investigate a Complaint to work at the direction of or in conjunction with the Audit Committee or any other person in the course of the investigation.
3. Unless otherwise directed by the Audit Committee, the person assigned to investigate will conduct an investigation of the Complaint and report his or her findings or recommendations to the Audit Committee. If the investigator is in a position to recommend appropriate disciplinary or corrective action, the investigator also may recommend disciplinary or corrective action.
4. If determined to be necessary by the Audit Committee, the Company will provide for appropriate funding, as determined by the Audit Committee, to obtain and pay for additional resources that may be necessary to conduct the investigation, including without limitation, retaining outside counsel and/or expert witnesses.
5. At least once each calendar quarter and whenever else deemed necessary, the Audit Committee will submit a report to the Board that summarizes any new Complaint made within the last 3 months and any outstanding Complaints that remain unresolved and shows specifically: (a) the complainant (unless anonymous, in which case the report will so indicate), (b) a description of the substance of the Complaint, (c) the status of the investigation, (d) any conclusions reached by the investigator, and (e) findings and recommendations.
6. At any time with regard to any Complaint, the Audit Committee may specify a different procedure for investigating and treating such a Complaint, such as when the Complaint concerns pending litigation.

Access to Reports and Records and Disclosure of Investigation Results

All reports and records associated with Complaints are considered confidential information and access will be restricted to members of the Audit Committee, the Company’s legal department, employees or outside counsel involved in investigating a Complaint as contemplated by these procedures. Access to reports and records may be granted to other parties at the discretion of the Audit Committee.

Complaints and any resulting investigations, reports or resulting actions will generally not be disclosed to the public except as required by any legal requirements or regulations or by any corporate policy in place at the time.

Retention of Records

All Complaints and documents relating to such Complaints made through the procedures outlined above will be retained for at least five years from the date of the Complaint, after which the information may be destroyed unless the information may be relevant to any pending or potential litigation, inquiry, or investigation, in which case the information may not be destroyed and must be retained for the duration of that litigation, inquiry, or investigation and thereafter as necessary.

Third party contractors

In the event that the Company contracts with a third party to handle Complaints or any part of the complaint process, the third party will comply with these policies and procedures.